GETTING RESULTS FROM COMPLEX FEDERAL PROGRAMS:
INTEGRATING PLANNING. POLICY AND MANAGEMENT AT EPA
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF POLICY, PLANNING AND EVALUATION
OFFICE OF MANAGEMENT SYSTEMS AND EVALUATION
DECEMBER
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FOREWORD
This paper describes innovations introduced in EPA's
management systems to respond to environmental and adminis-
trative challenges faced by the Agency. The ever-widening
scope of Agency responsibilities and the increasingly decen-
tralized nature of environmental protection operations require
a strong centralized management system for policy and oversight.
EPA's Strategic Planning and Management System (SPMS) provides
this centralized direction.
This paper has been designed to be useful to those both
inside and outside the Agency. Managers new to EPA may consult
the paper to understand the Agency's management systems.
Those outside EPA may find the paper valuable for understanding
EPA's management system and in some cases, adapting it to
similar situations in other institutions.
Several people participated in the development of this
paper. Eileen Sheehan wrote the paper. She received sub-
stantial support from Thomas Kelly, Cindy Kelly, Jim McCormick,
Joseph Retzer, Julie Tanner, Gainor Eisenlohr, and Arthur
Weissman, all of the Office of Policy, Planning and Evaluation.
Alvin L. Aim
Deputy Administrator
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EXECUTIVE SUMMARY
To manage EPA's increasingly decentralized operations,
diverse programs, and broad responsibilities, EPA created the
Strategic Planning and Management System (SPMS). SPMS performs
many of the same functions as a corporate strategic planning
system. Specifically, SPMS provides direction on goals and
priorities and offers guidance on work over a two year period.
The goals and guidance serve as the basis for development of
program commitments and work products. The final component of
SPMS is a system of follow-up to ensure that commitments are
met and problems resolved.
The Agency guidance articulates EPA's goals and objectives,
provides a clear articulation of EPA's direction and sets
priorities. To support the guidance and achieve the goals,
Regions and programs make commitments to take specific actions.
Then, the Agency uses reporting systems to monitor progress on
these commitments at Headquarters and in the Regions. The
Action Tracking System (ATS) tracks major regulations and
policies at Headquarters. The timely action by Headquarters
on these regulations and policies allows Regions and States to
meet their SPMS commitments. SPMS tracks the Regions' and
States' day-to-day environmental work such as issuing permits
and conducting inspections. The final component of SPMS is
the evaluation agenda, which initiates studies to examine
EPA's effectiveness in producing specific environmental results
and highlights Agency problems needing special review.
The SPMS calendar begins when the Agency issues the
guidance in February, followed by Federal-State negotiations
in the Spring. The negotiations result in commitments, which
are tracked in SPMS. To monitor progress on commitments, the
Deputy Administrator meets with Assistant Administrators
during quarterly reviews and with the Regions during semi-annual
reviews. The most important commitments are incorporated
into performance standards. Accomplishments during the year
are summed up in an accomplishments report. The results are
used for personnel evaluations and bonuses.
Overall, SPMS provides the centralized management system
for policy and oversight needed to manage the Agency's
decentralized operations and its diverse and delegated
environmental responsibilities. SPMS has opened lines of
communication throughout the Agency and with the Regions and
the States. In sum, SPMS communicates where the Agency is
going and exacts sufficient management discipline to ensure
that it will get there.
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INTRODUCTION
During 1983 and 1984, EPA's top management introduced a
series of changes in the Agency's operating systems to better
enable the Agency to,carry out its complex mission of environmental
protection. This paper describes these management innovations
as well as the complex management problems they are designed to
address.
The changes instituted in EPA's management systems and
organization were introduced to respond to the particular
difficulties the Agency faces. While management of any Federal
agency presents a unigue set of circumstances, problems, and
opportunities, implementation of national environmental programs
involves an especially complex set of conditions that almost
defy national, centralized management.
The complexity of EPA's work derives from the broad scope
of the Agency's responsibilities and from the increasingly
decentralized nature of environmental protection operations.
Environmental protection responsibilities shifted from a
centralized, largely Federal government operation in the 1970's
to a more decentralized, Federal-State network in the 1980's.
This change has resulted in one of the most extensive systems
of indirect management in the federal government. During this
period the range of Agency responsibilities also increased
dramatically as a number of new national programs were instituted
by Congress on top of existing programs in air and water.
BROAD SCOPE OF RESPONSIBILITIES
The sheer range of EPA's statutory responsibilities creates a
major challenge for management. The Agency has a diverse array of
legislative charges across the various environmental media (such as
air, water, land). In addition, it must cope with problems that
cut across the media or result from interrelationships among them.
Legislative Mandate;
EPA operates under legislative authority for air pollution
control, solid waste management, toxic substances control,
drinking water protection, water pollution control, pesticide
registration and regulation, and radiation protection, among
other areas. These broad responsibilities arise from nine
separate laws the Agency is charged with administering.
Though each of these comprehensive environmental protection
statutes address seemingly distinct problems, a considerable
amount of overlap exists. Some statutes promote protection of
a given medium/ whatever the threat (Clean Air Act, Clean Water
Act), while others promote protection from a given threat, whatever
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the medium (Federal Insecticide, Fungicide, and Rodenticide Act
and the Toxic Substances Control Act). Pollution in one medium
can eventually contribute to pollution in another.
Program Offices;
Implementing these diverse laws is the responsibility of
twelve separate line program offices in EPA Headquarters, directed
by four Assistant Administrators (AAs). Attachment A shows
these program offices as they are displayed on the Agency's
organizational chart. In addition there are eight other Headquarters
offices responsible for a variety of cross-programmatic, staff
and line functions, such as enforcement and compliance, policy,
research and development, and administration.
Managing twelve separate program offices, each with their
broad responsibilities, requires major direction and coordination.
This is especially true in the cases where, because pollution does
not respect neat statutory or organizational lines, the concerted
action of more than one program office is needed for effective
environmental management.
Protection of groundwater is a prime example. Groundwater
quality is affected by pesticides, solid and hazardous wastes,
and surface water problems such as non-point source pollution.
Groundwater quality, in turn, affects the quality of much of
our drinking water. Hence, an effective approach to groundwater
quality management must at a minimum involve and coordinate the work
of five EPA program offices.
In sum, EPA management systems must take into account the
Agency's broad legislative mandates, the organizational structure
that accompanies these diverse responsibilities, and the complex
interrelationships among media and program offices. These factors
can work to separate and slow down an organization. They
require a centralized, goal-setting management system to unify
and give clear direction to the organization.
DECENTRALIZATION
The diverse environmental media responsibilities are not
the only reason a strong management system is needed. The
second reason stems from a trend in the division of labor of
environmental protection. Over the last several years,
environmental protection has become increasingly decentralized -
both within EPA and across the nation. Within the Agency, work
has been decentralized from Headquarters' Offices to EPA's ten
Regional offices. At the same time, environmental protection
responsibilities have been increasingly decentralized from the
Federal government to State and local governments, resulting in
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one of the highest levels of decentralization of any Federal agency.
As environmental programs have become more decentralized, the
centrifugal forces pulling outward must be counterbalanced by
policy and oversight in a strong system of management providing
direction and priorities.
Decentralization Within EPA;
In addition to the twelve program offices in Headquarters,
EPA has ten Regional Offices, each directed by a Regional
Administrator (RA). Each Headquarters program office has a
counterpart in every Regional Office. So, for instance, the
Headquarters Air program office has a counterpart in each Region:
an Air Management Division headed by an Air manager. Attachment B
depicts the organizational structure of a typical Regional Office.
Headquarters and Regional Offices each have their own distinct
,set of responsibilities in environmental protection. Headquarters
program offices are responsible for developing national goals,
standards, regulations and policy. Regional Offices have primary
responsibility for implementing these policies and applying the
standards and regulations. The day-to-day implementation
responsibilities include administering grants, issuing permits,
monitoring compliance, and handling enforcement. So while
Headquarters program offices set national policies and standards,
the day-to-day operation of environmental programs is decentralized
and handled by the Regions. This decentralization heightens the
need for clear goals and overall direction from Headquarters
and sufficient flexibility for Regions to direct programs to
the most significant Regional problems. There is a natural tension
between national goals and Regional priorities that calls for
skillful management.
The geographic dispersion of Regional offices and the division
of responsibilities between policy development and program
implementation provide fertile ground for conflicting signals from
Headquarters and Regional program managers on Agency priorities.
Reforms in the Agency's management systems that emphasize clear
direction and priorities have sought to address this organizational
reality.
Federal/State Decentralization within the Nationwide Network;
When major environmental laws were passed in the 1970's
the Congress observed that States had uneven and, in some cases,
inadequate capability to undertake aggressive, effective
environmental protection programs. Consequently, these laws
assigned to the Federal government many of the key functions of
environmental protection. The laws did, however, provide for
delegation to the States.
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In the 1980's, the States are re-emerging as the central
players in environmental protection. State staff and authorities
have grown enormously in both magnitude and sophistication since
1970. Moreover, Congress has stipulated that the administration of
most Federal environmental programs will be carried out by
qualified States. In 1982 and 1983, the percentage of EPA's
programs delegated to the States nearly doubled. More than
half of the responsibilities eligible for delegation by EPA are
now being managed by States.
These changes mean that States are assuming more and more
of the day-to-day operating responsibilities once handled by
Regions, while Regions are taking on new responsibilities overseeing
the work of the States. In delegated national programs, the States
are primarily responsible for the delivery of environmental
services, while EPA Headquarters is primarily responsible for
environmental program design. EPA Regions handle oversight of
delegated States or implementation of programs in those States
unwilling or unable to assume responsibility for operation of
environmental protection programs. During the deliberations of
a 1983 task force on State/Federal relations, it was estimated
that States had over two people to every one the EPA had for
environmental protection.
In essence, Federal, State, and local governments are part
of a complex and interdependent national network for environmental
protection. Ultimately, though, EPA remains accountable to the
Congress for the protection of the environment by this network
and must still set direction and policies and monitor progress
towards national goals. These responsibilities and the nature
of this decentralized network require management systems that ensure
adherence to national environmental laws.
MANAGEMENT SYSTEMS DESIGNED TO DEAL WITH COMPLEXITY
EPA's top managers have made changes in several key management
systems in recognition of the complex and decentralized aspects of
environmental protection. The systems are intertwined, but will
be presented here in a way that highlights their separate functions.
The most extensive and detailed management system at EPA
is the Strategic Planning and Management System (SPMS). In addition,
there are other major Agency systems, which managers use to keep
this complex organization moving toward the goal of environmental
protection. These include the enforcement function and the
budget process. Both these systems are linked to SPMS.
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STRATEGIC PLANNING AND MANAGEMENT SYSTEM (SPMS)
The predominant system used to track progress and guide
the Agency in implementing its legislative mandates is SPMS.
SPMS provides a step-by-step process or framework for the Agency
to set goals and priorities, plan Agency and State actions, manage
and track performance, and identify areas for in-depth evaluation.
Figure 1 shows the SPMS calendar for FY'84-86. The calendar
identifies the major activities and critical dates in the annual
SPMS process. As indicated by the calendar, the process can be
divided into four general steps. Each step will be explained in
detail below.
STEP #1; LEADERSHIP PROVIDES CLEAR DIRECTION, GOALS, AND PRIORITIES
Annual Agency Goals;
A clear sense of purpose is essential to guide an organization
to success in any complex endeavor. SPMS provides this vision
of where EPA is heading in the Agency guidance. The guidance
gives Headquarters, Regions, and EPA1s State and local partners
a clear indication of the Agency's goals, operating objectives,
and priorities.
The first part of the guidance includes a statement of annual
Agency goals. These Agency goals seek to balance our efforts
to correct long-standing problems with efforts to anticipate
and address new ones. Specifically, EPA's FY'86 goals are:
Goal I; Redress previously neglected problems and restore
environmental quality to acceptable levels.
Goal II; Control the use of existing commercial chemicals and
pesticides that pose an unreasonable risk to health or the environment.
Goa1 III; Anticipate and prevent future environmental
problems and maintain current levels of environmental quality.
These fundamental environmental goals capture the mission of
EPA. As Peter Drucker says, they describe "what business we are
in" and provide a unifying direction for the many disparate
program and Regional offices.
These Agency goals are the top of a hierarchy of program goals,
objectives, and activities. Program goals and objectives articulate
what each program plans to accomplish to meet EPA's long-term
environmental goals and day-to-day operations. Attachment C presents
the FY'86 and '87 Operating Year Guidance and Agency goals.
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PIGURE 1: SPMS CALENDAR
MAJOR ACTIVITIES AND CRITICAL DATA
FY 84
FY 85
FY 86
GOALS & PRIORITIES
0 Issue Annual Agency Goals
0 Issue Agency Priority List
0 Revise Agency Priority List
OPERATIONAL PLANNING
0 Issue Agency Operating Guidance
0 Finalize Regional Connitments
0 Develop State/EPA Agreements
ACCOUNTABILITY
0 Negotiate SPMS coranitments
0 Issue quarterly reports
0 Conduct biannual Regional trips
EVALUATION
0 Conduct mid-year reviews
0 Conduct management reviews/
evaluations as needed
9/30
ONDJFMAMJJAS
10/31
1V15
9/30
11/2
-2/28
-6/30 9/30
11/1
6/30 9/30
2/1 5/1 8/1
ONDJFMAM J J A S
10/31
11/15
11/2
-2/28
11/1
2/1
9/30
-6/30 9/30
-6/30 9/30
5/1 8/1
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The Administrator's Guidance on Organizational Values;
The first section of the guidance also contains the
Administrator's personal statement of the fundamental principles
needed to meet EPA's goals efficiently and effectively. These
principles include the need for Agency employees to strive for
excellence in their work and EPA's need to strengthen its
partnership with the States. These principles identified by the
Administrator can be seen as similar to those espoused by the
Chief Executive Officer of a company. They prescribe fundamental
values for an organization, such as trust, openness, and the quality
of science that drive the Agency approaches and attitudes towards
management.
The Deputy Administrator's Operating Guidance:
The second part of the guidance is the Deputy Administrator's
detailed operating guidance, identifying operating goals, program
priorities, and a general approach to program management. In this
section, the Deputy Administrator highlights the incrementally
most important program activities that require the most management
attention and emphasis at the operating level to ensure EPA's goals
and objectives are met. Program managers make specific
commitments to achieving these priority activities that will be
tracked in the SPMS and incorporated in their individual
performance standards.
Specifically, for PY 1985-86, the Deputy Administrator's
guidance emphasized priority program activities in several major
areas: increasing enforcement and compliance efforts, increasing
regulation of toxic chemical substances, re-registration of pesti-
cides, implementing EPA's groundwater protection strategy,
addressing Superfund sites, issuing hazardous waste permits
and developing air toxics monitoring strategies.
Agency Priority List;
The next section of the guidance document lists the Agency's
priorities. Thse priorities are the product of extensive discussions
between the Agency's senior managers, industry representatives,
environmental groups, and State environmental directors. However,
the ultimate order is decided by the Administrator and Deputy
Administrator. The priority list helps the operating managers make
the necessary trade-offs they will inevitably face throughout
the year.
For example, in FY'85 the priority list included 31 key items.
The top priority on the list was the stabilization of imminent
threats at uncontrolled hazardous waste sites through Superfund
removal actions. Other top priorities included additional activities
to control hazardous wastes, expeditiously issue National Pollutant
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Discharge Elimination System (NPDES) permits, implement the
groundwater strategy, and work with the States to incorporate
non-point source control measures.
The priority list is revised and updated each year to reflect
accomplishments and emerging environmental issues. Specifically/
several changes were made in the FY'85 list in the course of
developing the FY'86 list. For instance, the 15th item on the
FY'85 list - promulgation of RCRA regulations - moved up to become
the sixth priority on the FY'86 list. This particular priority
calls on the Agency to "promulgate RCRA regulations and take other
action to strengthen the existing RCRA program and carry out RCRA
reauthorization reguirements." Similarly, the ninth priority on
the FY'85 list - reducing significant risks from existing
chemicals - has become the seventh priority on the FY'86 list.
Attachment D presents the FY'85 and '86 priority lists.
STEP #2: OPERATIONAL PLANNING FOR PROGRAM RESULTS
Program Operating Guidance;
The next step in the planning process is for the national
program managers to develop two-year operating guidance, consistent
with the goals and the priority list. For FY185-86, the guidance
development process was focused to ensure effective support of
the goal of unified environmental management with the States. The
resulting guidance document explicitly describes the direction of
the Agency over the next two years, the strategies programs use to
get there, and clear operating guidance to implement those strategies.
The second year guidance becomes the next year's operating guidance.
Two examples illustrate this detailed operating guidance.
The Office of Air and Radiation (OAR) took the Agency's FY'85 goal
of restoring environmental guality and identified objectives specific
to the Air program that relate to this goal. For example, they cited
as an objective the attainment of healthy air quality for the 150
million people living in areas that exceed the National Ambient Air
Quality Standards (NAAQS). This objective was to be met by completing
or revising SIPs that will correct measures that have proven inadeguate
to meet air guality standards by specific statutory deadlines.
Responsibility for achieving this objective is divided among
Headquarters, States, and Regions. For instance, States and Regions
are responsible for revising the SIPs to address new areas where
air quality is not being attained. Concurrently, Headquarters will
provide timely review of SIP corrections submitted by States and
reviewed by Regional Offices.
Two of the Agency's FY'85 goals were addressing previous
errors and restoring the quality of the environment to acceptable
levels. The Office of Solid Waste and Emergency Response (OSWER)
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translated these Agency goals into several objectives, one being
the plan to clean up existing uncontrolled hazardous waste sites.
This objective was broken down into a series of activities, including
site stabilization, removal and spill response. The Agency's
highest priority is the response to imminent threats to public health
and the environment posed by uncontrolled hazardous waste sites
and spills of hazardous substances into the environment.
Another example of EPA efforts to meet the goal of maintaining
current levels of environmental quality is found in the groundwater
policy. The new groundwater policy has a classification scheme which
gives highest priority to protecting pristine groundwaters that are
important for drinking water or ecological integrity. This policy
aims at preventing degradation of valuable groundwaters and
reflects the goal of maintaining current environmental quality.
The respective responsibilities of Headquarters, Regional
and State offices in meeting a goal depend on the particular
situation. For example, Regions will become involved in situations
where the responsible party or State is not equipped to deal
satisfactorily with a significant threat to human health or the
environment. The detailed operating guidance, illustrated by the
preceding two examples, thus delineates responsibilities of the
various participants in environmental protection.
Guidance Development/Uses of the Guidance
The development of this detailed guidance requires the
involvement of Regions and States in preparing the program strategies
which comprise the main body of the guidance. Regions and States
not only have the lead role in making commitments to meet the goals
spelled out in the guidance, they also play a central part in
establishing the evaluation measures which, in the aggregate,
comprise the national system of oversight.
The guidance is the foundation for other important Agency
activities. It shapes grant negotiations between Regions and States,
and serves as the underpinning for the Agency budget process.
Specifically, the priority list and Agency goals and guidance
frame the Deputy Administrator's call for preparing the Agency's
budget request. This is a marked improvement over the past
when the budget was built from the ground up, planning separately
for each of many small components of each program. The result
was that the Agency failed to establish and support, through the
budget, a clear thrust and direction.
An effective budget process must reflect knowledge of the
current performance of Agency programs. Managers need to know
what the return has been on earlier investments of people and
money. This link was missing without the follow-up or accountability
portipns of SPMS, to be described shortly. This data or tracking
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information, current to the most recent quarter, is available and
open to all participants in the budget process. Augmented by
special management reviews or evaluations occuring during the year,
it helps to pinpoint whether increased resources will actually
improve program performance.
Using the goals, guidance, and priority lists has substantially
strengthened the budget process. Each new budget now reflects
the priorities, operational realities, and policy decisions arrived
at through the SPMS process during the proceeding months.
Performance Commitments and Indicators of Progress;
Commitments for the year are negotiated by EPA Regions and
Headquarters programs with the Deputy Administrator. These
commitments are essentially performance agreements, and include
such items as issuing a target number of permits or inspecting
a percentage of suspected violators.
The national program offices in Headquarters review Regional
offices commitments. If differences arise, the Office of Regional
Operations helps adjudicate the differences. Headquarters program
offices also commit to specific actions, agreeing to complete a
given number of standards or policy documents. The Deputy
Administrator gives final approval to all the commitments. Any
amendments to the commitments or the guidance during the year
must be cleared by the Deputy Administrator.
The Agency's guidance is thus much more than a policy docu-
ment. It includes the specific measures that will be used to
determine success throughout the year. These measures are the
ones used to establish accountability within the Agency.
Questions inevitably arise about the measures selected to
assess program effectiveness, environmental improvement or the
success of environmental programs. While it is easier to rely
on strictly numerical measures of success e.g. the number
of permits issued the Agency tries to get as close as possible
to selecting indicators of EPA's qualitative as well as quanti-
tative progress or environmental performance.
As SPMS has matured, the quantitative tracking measures
have been supplemented with several measures that give some
indication of quality. For example, in addition to counting
the number of enforcement litigation cases referred to the
Department of Justice (DOJ), the Agency now tracks the number
of cases returned to EPA for reworking. Directing attention
to this qualititative measure has increased the volume of
cases referred while reducing the number returned by DOJ attorneys
as deficient.
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Another SPMS process change that aids EPA's ability to
measure performance quality has been in the way the Agency
tracks compliance with EPA standards and regulations. Tra-
ditionally, the Agency measured overall noncompliance rates
(e.g. the number of facilities not in compliance with Agency
standards). The Agency now singles out significant noncompliance
as well. EPA compiles a special list of significant violators
and tracks their performance until full compliance is achieved.
The list is continually updated, combining the backlog of
significant violators identified at the beginning of the year
with new listings as they are found. This measure prohibits
Regions and States from seeking to boost compliance rates by
bringing less significant violators into compliance, while
ignoring major violators. It also discourages frivolous
enforcement actions that will not lead to eventual compliance.
Thus, the second step in the SPMS process produces programs'
operating guidance and programs' commitments to achieve the
objectives spelled out in the Guidance. While the commitments
typically take a numerical form, the Agency has worked to
develop measures that provide qualitative as well as quantitative
indications of progress towards Agency goals.
STEP |3; MANAGEMENT TRACKING AND FOLLOW-UP
None of EPA's goals and priorities are very useful unless
there is a good system of follow-up. Tracking is the link
between plans and performance. SPMS carefully tracks progress
on annual commitments made by program AAs to ensure the
Agency is getting the desired results.
Establishing commitments in the SPMS involves careful
negotiation between Headquarters and the Regions. For example,
the AA for the Office of Solid Waste and Emergency Response is
responsible for the overall commitment to issue so many RCRA
permits. The AA must first negotiate with the Regions that
actually issue the permits. Differences between an AA and an
RA over commitments are resolved by the Deputy Administrator.
The SPMS then tracks the performance of each individual Region
as well as the performance of the AA.
Each quarter, SPMS produces a formal progress report for every
program area at the national, Regional and State levels. Quarterly,
the Deputy Administrator sits down with each Assistant Administrator
and comprehensively reviews his or her program's performance as
reflected in the SPMS quarterly report. The quarterly meetings
provide senior managers an opportunity to discuss Agency progress.
The managers focus on the accomplishments of and significant
problems encountered in the last quarter. Where the reasons for
significant slippages are not readily apparent, management reviews
are undertaken to identify necessary corrective actions.
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The Deputy Administrator cilso uses the quarterly report
as the basis for semi-annual visits to the ten Regional offices.
These visits provide constructive opportunities to discuss
each Region's performance and to assist managers in overcoming
problems in implementing programs. On these visits, the Deputy
Administrator meets with the RA and the Division Directors to
review their performance and to discuss strengths and weaknesses.
The visits provide Regional management an opportunity to discuss
with the Deputy Administrator real world problems encountered in
implementing programs and assistance needed from Headquarters.
The meetings give the Deputy Administrator a "reality check" on
Agency goals and expectations and alert him to areas needing
Headquarters' attention.
When possible, the Deputy Administrator also meets with
State environmental directors during his Regional meetings.
These meetings allow him to receive direct feedback on program
implementation from the State perspective and to reinforce the
direction the Agency has set for environmental programs.
Action Tracking System;
In support of SPMS and to ensure adherence to its schedule,
management has developed a complementary Action Tracking System
(ATS). The system primarily monitors Headquarters responsibilities
and progress on priority actions such as the development of major
regulations and standards, significant policy documents and
responses to court ordered deadlines. There may be several
hundred of these actions in the system at any one time since
it tracks each Headquarters action and identifies every over-
due item. Using data from the system, the Deputy Administrator
meets biweekly with Headquarters senior managers. The focus
of each meeting is on milestones due to be completed during
that period. Attachment E is a mock up of both summary and
detailed ATS reports.
By closely tracking priority Headquarters actions, ATS
enables EPA management to identify problem areas needing
management attention and to take steps to improve Headquarters
performance. Within one year of the implementation of ATS
in 1983, the Agency experienced a marked increase in its ability
to meet key deadlines. In 1984, the completion rate for regula-
tions improved by over 50%.
ATS allows top management to identify and resolve problems
at Headquarters that might otherwise prevent Regions and States
from meeting their SPMS commitments. For example, ATS helps
ensure more timely promulgation of guidance, such as the definition
of significant noncompliance, that enables Regions and States
to meet their program commitments.
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Enforcement;
An essential component of the Agency's follow-up and tracking
system is its compliance and enforcement effort. Recognition of
the singular importance of compliance and enforcement prompted the
establishment of a separate Office of Enforcement and Compliance
Monitoring (OECM) to oversee all EPA's national compliance and
enforcement efforts and to coordinate all supporting management
systems for these efforts.
This new analytical staff took several key steps in 1984 to
enhance compliance and enforcement in the Agency. First, OECM
recently worked with each program to develop individual program
enforcement strategies. These enforcement strategies provide a
clear statement of each program's compliance priorities, along
with problems which need to be addressed. The strategies are
reflected in the SPMS operating guidance mentioned earlier and
are used by Regions and States to establish workload commitments
for inspection and enforcement actions.
OECM also ensures progress on compliance and enforcement by
use of State/Federal Enforcement "Agreements," which were put in
place at the beginning of FY'85. These Agreements are designed
to spell out clear oversight criteria that States, Regions, and
Headquarters all agree will be the basis for determining how well
each organization is performing. In addition, these "Agreements"
are designed to foster better State reporting overall.
OECM also took important steps in 1984 to reach agreements
among the relevant parties on definitions of several key enforce-
ment concepts. In a national Policy Framework, OECM clearly
laid out what constitutes "timely and appropriate" enforcement
response and clarified what is considered appropriate action in
certain enforcement situations.
Another important element in OECM's work is the use of
Significant Violators Lists. OECM defined what constitutes a
significant violator for each program, and now tracks these
violators until they have returned to full physical compliance.
As mentioned earlier, the Agency tracks both the beginning
of the year backlog of significant violators not yet brought into
compliance and new significant violators as they are found - both
a static and dynamic picture of Agency progress. Thus, through
constant updating, the significant non-complier lists are a
continuing management tool.
STEP |4; PROGRAM EVALUATION
For the most part, the elements of SPMS are aimed at
effective direction and control of the day-to-day work of
environmental protection. However, for a management system
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to be complete it must make provision for the need to step back
from the problems of today and re-examine the structure and
achievements of environmental programs over time. For this reason
EPA instituted in 1984 a process for selecting and conducting
formal, retrospective program evaluations on a regular basis.
EPA has a long tradition of constructive, problem-solving
program evaluation, a function that is lodged with the Assistant
Administrator for Policy, Planning and Evaluation. OPPE's Office
of Management Systems and Evaluation (OMSE) has for many years
been targeting problems in program performance and using the
tools of program analysis to diagnose causes and implement fixes.
Typically, this was done at the request either of the program
managers involved or of the Administrator or Deputy Administrator.
While this approach proved practical and valuable it had some
innate weaknesses. First, if the reguest came from the top,
it implied some public criticism of program management? if the
Administrator or Deputy were not worried about something, they
would not order the study. Second, to the extent it relies on
program managers to invite external review of their programs
it counts on an unlikely (though surprisingly frequent) set of
circumstances to trigger an evaluation.
Under the new approach OMSE retains its ability to under-
take program evaluations on call, but also cooperates with
line program managers in conducting program evaluations chosen
and scheduled systematically. Each year the Deputy Administrator
invites program Assistant Administrators to propose major programs
or program elements within their span of control to be the topics
of evaluation. The criteria applied to candidate topics are:
0 The issue or program area is included on the Agency's
current priority list, or is otherwise important to
achieving environmental results;
0 There is some evidence of a suspected management problem
identified through SPMS or by State, Regional, or other
sources; and
0 The issue is ripe for attention as manifest by senior
management's attention or the absence of a recent review.
In addition, candidate topics are solicited from EPA Regions,
State program officials, and OPPE.
With this list in hand, the Deputy Administrator then
conducts a decision meeting with the program Assistant Adminis-
trators. There they review the topics and decide which are most
subject to analysis likely to produce improvements in program
performance. They also decide who should have lead responsi-
bility for the study the program office itself, or the
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-15-
central program evaluation staff.
The result of this process is a commitment to program
evaluation studies of genuine importance to the Agency, an
investment by program managers in appraisal of their own
programs' performance, and the maintenance of a procedure by
which evaluations get selected, planned, and carried out
routinely, without a sense of crisis surrounding the issue.
And, while it is not possible for each EPA program to undergo
a thorough evaluation each year, or even every two or three years,
the existence of a consistent, regular process of self-examina-
tion in even a sample of Agency programs lends an added element
of integrity and objectivity to all of EPA's proceedings.
The addition of this evaluation component constitutes the most
recent change made in SPMS by management and it completes the
Agency's integrated planning and management system.
CONCLUSION; EPA'S MANAGEMENT SYSTEM DESIGNED TO MEET THE
AGENCY'S UNIQUE SITUATION
Decentralization and delegation of day-to-day environ-
mental responsibilities, in combination with the Agency's
wide range of environmental responsibilities, heighten the
need for a centralized management system for policy and
oversight.
SPMS provides the structure for strong leadership and
coherent management with its goal setting, planning, tracking
and evaluation functions. SPMS also makes the necessary links
to other Agency systems such as budget and enforcement.
Although SPMS contains some elements common to those of
any organization's management systems, it is tailored to the
specific requirements of the Agency's mission and relationship
with the Regions and the States.
Specifically, the Agency guidance, with its statement of
goals and objectives, provides a clear articulation of EPA's
direction. The guidance frames Agency objectives and sets
priorities, and thus drives resource allocation decisions
during the budget process. To support the guidance and goals,
the Agency relies on reporting systems to keep actions moving
at Headguarters and the Regions. The Action Tracking System
or (ATS) tracks the progress of major regulations, standards, and
policies which are developed primarily at Headquarters. The
timely development of these basic program tools by Headquarters
enables the field - Regions and States - to meet their commit-
ments spelled out in SPMS. SPMS commitments govern the day-to-
day operation of environmental programs, including such work as
issuing permits and conducting inspections.
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-16-
The final component of the system is the evaluation agenda
process, which allows management to take a closer look behind
the numbers provided by SPMS to ensure that EPA's programs are
truly effective in producing environmental results. This evalu-
ation agenda also affords management the opportunity to highlight
environmental, management or resource problems deserving inten-
sive review.
In short, SPMS provides a view of where the Agency is
going and how it is to get there. It takes into account the
decentralized nature of EPA programs and allows the Regions and
the States an opportunity to shape major policy which they will
eventually implement. The system assures clear agreement on
both EPA's objectives and a system of oversight and builds in
an accountability system necessary to success. It provides a
built-in opportunity, in the evaluation agenda process, to
scrutinize and correct problem areas and assess environmental
progress. Finally, SPMS supports the Agency's budget and the
crucial compliance and enforcement activities.
Management systems alone, of course, do not produce
results. Results can come only when a skillful and dedicated
Agency staff, working in partnership with a community of
environmental public servants in State and local governments,
devotes its best effort to addressing the complex problems of
environmental protection. However, the value of even the best
effort is diminished if the Agency has little ability to direct
this effort where it is most needed or to tell whether it is
having the intended effect. SPMS provides the rigor and discipline
needed to steer the Agency along a productive course in protecting
and enhancing the quality of the Nation's environment.
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APPENDIX
ATTACHMENT A: Agency Organizational Chart
ATTACHMENT B: Regional Office Organizational Chart
ATTACHMENT C: FY'86 and '87 Operating Year Guidance
ATTACHMENT D: Agency Priority Lists for FY 85-86 and 86-87
ATTACHMENT E: Summary ATS Report
Detailed ATS Report
Detailed ATS Schedule
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ATTACHMENT A; Organizational Chart
U.S. ENVIRONMENTAL PROTECTION AGENCY
STAFF OF I ICES
ADMINISTRATIVE LAW JUDGES
CIVIL RIGHTS
SMALL & DISADVANTAGED
BUSINESS UTILIZATION
SCIENCE ADVISORY HOARD
ADMINISTRATOR
DEPUTY
ADMINISTRATOR
ASSISTANT
ADMINISTRATOR FOR
ADMINISTRATION AND
RESOURCES MANAGEMENT
OFFICE OF THE
COMPTROLLER
OFFICE OF
ADMINISTRATION
OFFICE OF
INFO. RESOURCES
MANAGEMENT
OFFICE OF
ADMINISTRATION
CINCINNATI. OH
OFFICE OF
ADMINISTRATION
RTF. NC
ASSISTANT
ADMINISTRATOR FOR
ENFORCEMENT AND
COMPLIANCE
MONITORING
ASSISTANT
ADMINISTRATOR FOR
WATER
OFFICE OF WATER
ENFORCEMENT
AND PERMITS
OFFICE OF WATER
REGULATIONS
AND STANDARDS
OFFICE OF WATER
PROGRAM
OPERATIONS
ASSISTANT
ADMINISTRATOR FOR
SOLID WASTE AND
EMERGENCV RESPONSE
OFFICE OF
SOLID WASTE
OFFICE OF
EMERGENCV AND
REMEDIAL RESPONSE
OFFICE OF
WASTE PROGRAMS
ENFORCEMENT
OFFICE OF
DRINKING WATER
IAi.SOCIATt ADMINISTRATOR
FOR INIhHNATIONAI ACTIVITIES
ASSOCIATE ADMINISTRATOR
FOI! REGIONAL OPERATIONS
ASSISTANT
ADMINISTRATOR FOR
POLICY. PLANNING
AND EVALUATION
OFFICE OF
POLICY ANALYSIS
OFFICE OF
STANDARDS
AND REGULATIONS
OFFICE OF
MANAGEMENT
SYSTEMS AND
EVALUATION
ASSISTANT
ADMINISTRATOR FOR
EXTERNAL AFFAIRS
Mi
Wtf
OFFICE IF INTER-
GOVERNMENTAL
LIAISON
OFFICE OF
CONGRESSIONAL
LIAISON
OFFICE OF
PUBLIC AFFAIRS
OFFICE OF
FEDERAL
ACTIVITIES
ASSISTANT
ADMINISTRATOR FOR
AIR AND RADIATION
OFFICE OF AIR
QUALITY PLANNING
AND STANDARDS
OFFICE OF
MOBILE SOURCES
OFFICE OF
RADIATION
PROGRAMS
ASSISTANT
ADMINISTRATOR FOR
PESTICIDES AND
TOXIC SUBSTANCES
M
M
OFFICE OF
PESTICIDE
PROGRAMS
OFFICE OF
TOXIC SUBSTANCES
INSPECTOR
GENERAL
OFFICE OF
AUDIT
OFFICE OF
INVESTIGATIONS
OFFICE OF
MANAGEMENT AND
TECHNICAL
ASSESSMENT
ASSISTANT
ADMINISTRATOR FOR
RESEARCH AND
DEVELOPMENT
rm
-
OFFICE OF MONITOR-
ING SYSTEMS AND
QUALITY ASSURANCE
OFFICE OF
ENV. ENGINEERING
AND TECHNOLOGY
OFFICE OF
ENV. PROCESSES &
EFFECTS RESEARCH
1 OFFICE OF
HEALTH RESEARCH
REGION I
BOSTON
REGION II
NEW YORK
REGION III
PHILADELPHIA
REGION IV
ATLANTA
REGION V
CHICAGO
REGION VI
DALLAS
REGION VII
KANSAS CITY
REGION VIM
DENVER
REGION IX
SAN FRANCISCO
REGION X
SEATTLE
CK, '» 1983
/*//(
William n. A'xi/l.
-------
ATTACHMENT Bi Regional Organization Chart
AUTHORIZED EPA REGIONAL ORGANIZATION
REGIONAL ADMINISTRATOR
DEPUTY REGIONAL ADMINISTRATOR
Office of
Regional
Counsel
Water
Management
Division
Public
Affairs
Congressional and
Intergovernme ntal
Liaison
Office of Assistant Regional
Administrator for
Policy and Management*
Equal Employment
Opportunity Officer
Air and Waste
Management
Division**
Environmental
Services
Division
* Alternative Regional organization may reflect Management Division concept.
** Alternative Regional organization may reflect separate divisions for Air and Waste Management functions.
-------
ATTACHMENT C; FY'86 & '87 Operating Guidance
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
NOV211984
MEMORANDUM
m.t>->j.\^>i.
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-2-
overall goals. Program activities, such as establishing and enforcing
standards, are the means to achieving those goals.
Most of our program goals are defined by the statutes we
implement. For the air and water programs, the law is fairly
specific about our goals to the extent of establishing deadlines
for attainment of technical requirements (e.g., BPT, BAT) or actual
ambient standards (e.g., NAAQS). For other programs such as the
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), Toxic
Substances Control Act (TSCA), Superfund, and to some extent the
Resource Conservation and Recovery Act (RCRA), we have more flexiblity.
Writing the FY 1986 Guidance
For the FY 1986 Operating Guidance, I want each program to
develop a framework of program goals and objectives consistent with
the relevant EPA goals. The attached outline sets forth program
goals and objectives. Following last year's model, programs should
introduce the more detailed guidance with a discussion of the
program's overall goals and objectives in a brief "strategy" section.
A couple of pages should be sufficient to convey "what is our
business," as Peter Drucker would say, in terms of these goals and
major objectives.
In the main text, the programs should follow the structure of
goals and objectives as closely as possible and further clarify how
they are going to achieve these goals and objectives through
appropriate program activities. The Operating Guidance is an
important opportunity to articulate the relationship between our
day-to-day activities and longer-term environmental goals and
objectives. As explained further below, the hierarchy of goals,
objectives, and activities should help tie these things together.
I. FRAMEWORK OF GOALS
Fundamental EPA Goals
Reflecting on the discussion at the Regional Administrator's
meeting in Seattle, I have refined last year's three goals as
follows:
Goal I. Redress previously neglected problems and restore
environmental quality to acceptable levels.
Goal II. Control the use of existing commercial chemicals and
pesticides that pose an unreasonable risk to health or the
environment.
Goal ill. Anticipate and prevent future environmental problems
and maintain high levels of environmental quality.
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-3-
Most programs have elements that fall logically under more
than one of these goals. For example, Goal I would encompass many
elements of the Clean Air Act (e.g., State implementation plans,
hazardous air pollutants) and the Clean Water Act (e.g., effluent
guidelines and NPDES permits). It also would include permitting of
existing hazardous waste facilities under RCRA and cleaning up
uncontrolled sites under Superfund.
Goal II is designed to encompass major elements of,the program
to identify and address harmful chemical^substances under TSCA as
well as reregister, suspend or cancel pesticides under FIFRA.
Goal III would embrace elements from all of our statutory
programs designed to maintain current environmental standards and
prevent degradation. For example, each of the following activities
contributes to the goal of preventing future environmental problems:
new source performance standards in air, ground-water protection
over sensitive aquifers, premanufacture review of new chemicals,
and registration of new pesticide products.
Program Goals
As the first tier below the three EPA goals, program goals
translate the fundamental goals and provide more strategic guidance
for each program. In most cases, program goals would be derived
from or closely related to the relevant statutory mandates. For
example, an illustrative program goal for the air program is to
bring nonattainment areas into compliance by the statutory deadlines.
The attached outline of EPA's goals provides^some illustrative program
goals.
Program Objectives
The next tier are program objectives. As illustrated in the
outline, program objectives translate the general program goal and
provide guidance on what actions to take to meet the more general
goal. For example, a program objective for the air program is to
assure requirements of State Implementation Plans are fulfilled
consistent with statutory deadlines (1982 and 1987). Another objec-
tive is to promulgate and endorse standards for mobile sources.
Both of these objectives support the goal above to bring nonattain-
ment areas into compliances by the statutory deadlines. To the
extent possible, programs should define objectives that set quanti-
fiable targets or specific milestones over the next few years or
so.
Program Activities
The bottom tier of the hierarchy are program activities which
include short-term actions to be completed within the two planning
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-4-
years (i.e., FY 1986 and FY 1987) that will bring EPA closer to its
broader goals and objectives. Examples of program activities for
the air program are to conduct inspections of all Class 1A sources
or to bring significant noncompliers into compliance. The program
activities provide the basis for the Strategic Planning and Management
System's commitments for tracking in FY 1986.
In conclusion, I want the program offices to develop their
guidance by working logically from our fundamental environmental
goals to increasingly more specific program objectives and activities.
The guidance should establish a framework for managers that clarifies
the relationship between our day-to-day activities and broader
environmental goals. The following is some general guidance for
preparing the FY 1986 - 1987 Guidance.
II. GENERAL GUIDANCE
Regional Review and FeedbacK.
In an earlier memorandum (September 6, 1984), I asked the
Regions to review the Operating Guidance for FY 1985 and FY 1986.
While the Regions have had only six months to test the usefulness
of the FY 1985 guidance, I am sure they will be able to provide
some constructive criticism for the next iteration. Program offices
developing guidance should be sure to take the lead Region's advice
into account before preparing the FY 1986 Guidance. To the extent
possible, Regions and Headquarters should solicit comment and
advice from the States throughout the process.
FY 1986 Priority List and General Guidance
The attached list of priority activities was developed based
on the Regions' review of last year's priority list, comments
from Headquarters offices, and consultation with outside groups.
The final order reflects what the Administrator and I believe
are the most incrementally important objectives to accomplish in
FY 1986. As in last year's guidance, programs should ensure that
the activities on the priority list receive special emphasis.
Programs should relate these activities to EPA's overall goals as
well as the programs' goals and objectives. In addition, programs
should include other activities not included on the priority list
that are essential to fulfilling these goals.
An important goal for FY 1986 and 1987 is to continue the
momentum we have established in FY 1984 in compliance and enforcement
activities by both EPA and the States. We must continue to improve
our compliance and enforcement strategies and effectively implement
the State/EPA enforcement agreements to meet our goals.
In all our programs, we must work to strengthen pur alliance
with the States. Our major goal is to promote successful State
operation of legally sound, high-quality programs. As we delegate
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-5-
greater operating responsibility to the States, we must respond to
States' needs for increased technical assistance and management
support. At the same time, we must improve our procedures for
evaluating and assessing our delegated programs and for taking
appropriate action when performance substantially lags commitments
in State/EPA Agreements.
The problems of hazardous waste continue to be at the top of
our priority list. With the RCRA reauthorization, promulgating
regulations and taking other actions to implement the new require-
ments are among the Agency's highest priorities. A major effort
must be undertaken by a number of EPA offices to implement this new
legislation.
In FY 1986, I want to place increased emphasis on the problem
of pesticides and toxic substances. We must make full use of our
authority under TSCA to regulate existing chemicals and accelerate
our efforts to reregister pesticide products.
In the water program, the tasks of reissuing the NPDES permits
and implementing the municipal strategy and pretreatment program
will all continue in FY 1986. Because of the importance of these
activities to attaining and maintaining water quality, they must
continue to be a very high priority.
Another high priority is building and enhancing ground water
protection programs at the State and local levels. Programs must
work closely with the Office of Ground Water Protection and fully
exercise their authority to control ground water contamination as
appropriate. We must also continue research to determine the
health effects, fate, and transport of contaminants in ground
water.
Similarly, we cannot relax our efforts to strengthen and
enforce ambient air quality standards for conventional pollutants,
particularly ozone. At the same time, we should make significant
progress in developing and implementing an air toxics monitoring
and control strategy.
ORD's role is critical to regulatory, standard setting, and
enforcement activities in many priority programs for FY 1986:
RCRA, Superfund, NPDES permits, biomonitoring, NAAQS, air toxics,
drinking water, acid deposition, ground water, dioxin, and wetlands,
for example. In FY 1984, the Office of Research and Development
established an excellent record of delivering products on time to
client offices. We must now improve the front-end of the process.
Planning for FY 1986 and FY 1987 is an excellent opportunity for
programs to work with ORD on shaping their research needs for the
future.
Finally, while monitoring may not be included on the priority
list per se, we must continue to examine our current monitoring
strategies;? An essential step in improving monitoring is to incor-
porate quality assurance programs to ensure we collect reliable
environmental data. In addition, an important element of our
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-6-
programs is the ability to detect new or emerging problems. We
must continue to design and implement "early warning" systems as
part of our monitoring programs.
There are a few additional areas that deserve emphasis in
planning for FY 1986 and FY 1987. First, as we are developing
regulations and policy guidelines and negotiating grants and con-
tracts, we must take into account the special circumstances of
small business. We will shortly be providing you more guidance in
this area. In addition, we need to maintain constant vigilance to
ensure the fiscal integrity of our operations. With the Superfund
and construction grants programs, EPA is responsible for overseeing
billions of dollars of projects. It is critical that staff at
every level carefully manage these accounts.
A major new initiative which we are beginning in FY 1985, and
which will carry over into the next several years, is the Indian
Program. Each media program manager should specifically incorporate
appropriate program objectives and activities which implement the
goals as outlined in the recently issued Indian Policy.
In developing the Operating Year Guidance, we must also carefully
plan for changes in our workforce. What steps must we take to
ensure the right level and mix of skills in the future? The program
managers should work closely with the Office of Administration and
Resources Management in this effort.
Finally, EPA's legislative agenda will be particularly important
in FY 1986 as the new Congress must address the reauthorization of
many of our major statutes.
Environmental Management Report Updates
I expect the program offices to carefully review the
Environmental Management Report updates that the Regions submitted.
These reports describe each Region's most significant environmental
problems and the Headquarters actions needed to address them. To
the extent possible, the operating guidance should take these
requests into account.
Process and Schedule for Guidance Development
This memorandum officially begins the guidance development
process. I was pleased with last year's Guidance, but hope that we
can do even better this time to present clear and constructive
guidance to the Regions and States. Like last year, the guidance
will contain an Appendix with performance measures for the Strategic
Planning and Management System (SPMS). The lead Regions should be
involved this year in the process of setting those measures. It is
important to get the measures agreed to well in advance of beginning
negotiations for commitments. The schedule for the guidance process
with key dates for the rest of the year is attached.
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As I have said publicly many times over the course of the last
year, EPA now has one of the best management systems in government.
The Agency Operating Guidance is the backbone of the system. The
modifications I am proposing for next year's guidance attempt to
refine and perfect a product which is already an extremely effective
management document. I look forward to reviewing your FY 1986-1987
guidance.
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EPA GOALS
GOAL I:
Redress previously neglected problems and restore environmental
quality to acceptable levels.
Program Goals;
Goal I encompasses most elements of CAA (SIP process, hazardous air
pollutants), CWA (effluent guidelines and permits), RCRA (permitting
and Superfund). Program goals are:
Air
0 Achieve air quality standards in nonattainment areas by
statutory deadlines.
0 Reduce risk of exposure to hazardous air pollutants.
Water
0 Achieve water quality that meets fishable/swimmable standards
to extent feasible.
0 Reduce risks to public health from exposure to toxic pollutants.
Drinking Water
0 Reduce public health risks from drinking water that fails to meet
Federal standards (deadlines based on applicability of different
standards).
RCRA
0 Reduce or eliminate risks from disposal of hazardous wastes.
Superfund
0 Reduce or eliminate risks from uncontrolled hazardous sites.
Program Objectives;
Air
0 Assure requirements of State Implementation Plans are
fulfilled consistent with statutory deadlines (1982 and 1987).
0 Promulgate and enforce technical standards for mobile sources.
0 Implement a hazardous waste program (sec. 112 standards and
assistance to States).
Water
0 Achieve compliance with technology-based standards by 1988.
0 Achieve municipal compliance by 1988.
0 Make as much progress on controlling nonpoint sources as possible.
Drinking Water
0 Achieve highest possible compliance rates with microbiological,
turbidity, and new regulations for drinking water.
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2
RCRA
0 Propose priority regulations and fulfill other key requirements
of the reauthorized RCRA.
0 Permit or close land disposal and incineration facilities
(by some date); finish with storage and treatment (by a later
date).
Superfund
0 Address sites on the National Priority List (by some date).
0 Continue to stablize imminent threats at uncontrolled
hazardous waste sites through expeditious removal actions.
Key Program Activities;
A. Establish Standards
1. Scientific (R&D and other technical analysis)
2. Regulatory support (legal, economic, operational)
(e.g., water quality standards and effluent guidelines)
B. Issue Permits
1. Delegation and oversight for State issuance
2. EPA issuance
(e.g., NPDES permits)
C. Monitor Progress
1. Inspections and self-monitoring reports
2. Ambient monitoring
(e.g., self reporting and biomonitoring)
D. Inform Public of Hazards
(e.g., health advisories informing consumers of
drinking water violations)
E. Compliance and Enforcement Activities
F. Assist in Financing of Clean-up
(e.g., Superfund and construction grants)
GOAL II;
Control the use of existing commercial chemicals and pesticides
that pose an unreasonable risk to health or the environment.
Program Goals;
Goal II encompasses FIFRA and TSCA programs and pollution from toxic
chemical manufacture (e.g., Section 112 of CAA) would be under Goal I.
Program goals are:
TSCA
0 Reduce or eliminate unreasonable risks from existing commercial
chemical substances.
FIFRA
0 Protect health and the environment from any unreasonable
adverse affects from pesticides currently in use.
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Program Objectives;
TSCA
0 Test and conduct risk assessments on (a certain universe of)
suspect chemicals.
0 Take appropriate regulatory actions on chemicals that present
unreasonable risks to human health and the environment.
FIFRA
0 Reregister (85 percent of the volume) of pesticide products in
commerce by 1990.
0 Establish appropriate tolerances for pesticides whose residues
on food products may pose chronic health effects.
0 Restrict or ban the use of pesticides posing a threat to human
health and the environment.
Key Program Activities;
A. Identify Harmful Chemicals
1. Testing (section 4, NTP,' Guidelines, audits)
2. Information Gathering (all section 8)
3. Other (Human Monitoring, New Chemicals, etc.)
B. Evaluate Harmful Chemicals
1. Exposure or Monitoring Studies
2. Risk Assessment/Risk Benefit Balancing
3. Other (SNURs/8(a) rules under TSCA)
C. Manage Harmful Chemicals
1. Restrict or control (section 6)
2. Referral (Section 9)
3. Other (advisories under TSCA)
4. Technical Assistance
5. Integration
D. Inform Public of Hazards
E. Compliance and Enforcement Activities
F. Research and Development
GOAL III;
Anticipate and prevent future environmental problems and maintain
high levels of environmental quality.
Program Goals;
Program goals are;
Air
0 Prevent significant deterioration of air quality.
0 Prevent reversion of areas which have come into attainment.
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-4-
Wat.er
0 Maintain fishable, swimmable and other standards when attained.
Drinking Water
0 Prevent deterioration of the quality of drinking water.
Ground Water
0 Prevent deterioration of ground water quality.
0 Develop and implement siting regulations.
0 Develop technical standards that protect ground water
from contamination in future.
RCRA
0 Prevent risks from hazardous waste disposal operations and
sites in the future.
TSCA
o prevent risks from new chemical substances and significant
new uses of existing chemical substances.
0 Prevent unreasonable risks from new pesticide active ingredients
anc products and encourage safer new products.
Wetlands
0 Protect valuable wetlands to assure biologic productivity and
ecosystem stability.
Program Objectives;
Air
0 Monitor State programs to prevent sig'nificant deterioration
of air quality and take action where States have failed to act.
0 Maintain an effective air compliance monitoring and enforcement
program.
Water
0 Maintain continuous compliance in facilities that have achieved
initial compliance.
0 Assure new sources meet applicable technology or other
standards.
Ground Water
^ Implement the ground-water protection strategy.
Drinking Water
0 Establish standards and issue health advisories for contaminants
of concern in drinking water.
RCRA
0 Achieve over 90 percent rate of compliance by major hazardous
waste handlers with RCRA regulations (by some date) .
TSCA
0 Subject all new chemicals to a meaningful review taking action
on those that pose an unreasonable risk.
-------
FIFRA
0 Design and implement an effective national pesticide monitoring
program to detect unaddressed environmental and health problems.
0 Provide careful review to assure that new pesticides do not
add to total risks.
0 Provide expeditious review of pesticides that will replace
more toxic, existing chemicals.
Wetlands
0 Establish a system to classify and protect the most important
wetlands.
Key Program Activities;
A. Premanufacture Review, etc.
1. Review New Chemicals
2. Control Unreasonable Risks from New Chemicals
3. Track commercial development of potentially harmful
new chemicals
4. Encourage industry development of data on new chemicals
(section 5(b)(4) rule)
5. Improve decisionmaking tools (SAR Study)
B. Siting Controls (404 reviews for wetlands and locational
guidance for new hazardous waste facilities)
C. Establish New Source Pollution Standards
1. Science
2. Other regulatory development (legal, economic, operational)
D. Monitoring
1. Inspections and self-monitoring reports
2. Ambient monitoring
E. Compliance and Enforcement Activities
F. Review Impacts of Future Projects (EIS review, environmental
assessments)
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ATTACHMENT D
FY'85-86
AGENCY PRIORITY LIST
1. Stabilize imminent threats at uncontrolled hazardous waste
sites through Superfund removal actions.
2. Use the Superfund remedial program to complete longer term
complex site cleanups through fund financed actions.
3. Take enforcement actions to reduce the number of RCRA Class I
violations by major hazardous waste handlers and enforce
compliance with issued permits, paying special attention to
groundwater monitoring, closure, and post closure require-
ments.
4. Issue Part B RCRA permits, giving greatest priority to those
facilities where there are the greatest potential environ-
mental risks.
5. Implement an acid deposition strategy.
6. Implement the groundwater strategy in coordination with EPA
programs with groundwater responsibilities. Assist State
groundwater programs, improve the groundwater data base,
and work closely with other Federal agencies.
7. Reissue NPDES permits expeditiously. Apply the new treatment
requirements contained in the revised effluent guidelines and,
where necessary, water quality based limits beyond BAT. In
conjunction with this, develop and implement water toxics
monitoring and control strategies addressing toxics in both
surface water and sediment.
8. Negotiate responsible party cleanup at Superfund enforcement-
lead sites and pursue cost recovery actions for sites cleaned
up with Federal funds.
9. Under the TSCA existing chemicals program, initiate and
promulgate regulatory actions for the most significant
risks. In particular, address hazards from asbestos by
strengthening the asbestos in schools program and promulgating
and enforcing other regulations to address commercial manu-
facture, use of asbestos products, and exposures to asbestos
in public buildings or ambient air (under CAA) as necessary.
10. Promulgate Phase I (VOC) of the drinking water standards.
Expand the program of issuing health advisories for unregula-
ted contaminants in support of Superfund cleanup activities,
State agencies' responses to contamination incidents, and
other purposes.
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11. Conduct special reviews of pesticides suspected of causing
adverse health and environmental effects and initiate
cancellation and suspension actions as appropriate.
12. Protect the wetlands through vigorous attention to Sec. 404
reviews.
13. Develop and implement air toxics monitoring and control
strategies. Specifically, develop new NESHAPS and provide
States with technical support in areas such as ambient
monitoring, stack tests, and specific chemical risk
assessment.
14. Implement the dioxin strategy developed in FY 1984.
15. Promulgate RCRA regulations and take other actions to
strengthen the existing RCRA program and anticipate RCRA
reauthorization requirements. In particular, address
alternatives to land disposal for hazardous wastes, high
priority waste handlers, and materials not covered under
existing regulations.
16. Improve compliance of all major NPDES facilities and imple-
ment the municipal strategy to assure the construction and
effective operation of municipal facilities.
17. Manage the construction grants program to ensure that
resources are directed to projects with the greatest water
quality benefit.
18. Complete the review and revision of NAAQS as necessary
and support development of corresponding State control
plans. Monitor implementation of revised SIP schedules
for attainment of primary lead, particulate matter, ozone,
Sulfur dioxide NOX and CO NAAQS in nonattainment areas.
19. Work with States to incorporate nonpoint source control
measures in their water quality programs, where nonpoint
source pollution is a major problem, and assure provision
of technical assistance from the Department of Agriculture.
20. Ensure the Federal Government shows leadership in environ-
mental control practices through Federal facility compliance
with air, water, toxics, and hazardous waste requirements.
21. Increase development of high priority NSJPS, proposing and
promulgating more standards than in FY 84.
22. Implement the pretreatment program to control pollution from
indirect discharges and approve State and local pretreatment
programs, focusing first on those with discharges of greatest
environmental concern.
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-3-
23. Work with States to develop and achieve high quality
programs under interim and final RCRA authorization.
Make every effort to assist States in meeting the statu-
tory deadline for final RCRA authorization.
24. Subject new chemicals under TSCA to a meaningful review
using the PMN process to ensure that health and environ-
mental risks are adequately characterized and necessary
control measures are required.
25. Increase continuous compliance by facilities with air
standards, especially with standards for VOCs and other
gaseous pollutants not amenable to simple opacity tests.
26. Achieve compliance with PCS rules and regulations focusing
inspections and enforcement actions on the greatest
potential sources of harmful PCB exposure.
27. Implement an underground injection control program focusing
permit issuance on those existing facilities that present
the greatest threat to underground sources of drinking water
and on those new facilities which must be permitted to
prevent an unnecesary adverse impact on oil and gas production
Implement the ban on underground injection of hazardous waste
into or above an aquifer.
28. Prepare program and technical regulations to implement a
program for management, disposal, and reuse of municipal
sewage sludges.
29. Ensure in-use vehicle compliance through assisting States
with their anti-tampering and lead fuel switching programs
and by conducting audits of inspection and maintenance
programs.
30. Promulgate Phase II (Revised Regulations) of the drinking
water standards and ensure compliance by public water
systems with applicable standards.
31. Thoroughly review the projected environmental impacts of
proposed Federal projects and regulations under Section 309.
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AGENCY PRIORITY LIST FOR FY 1986-87
1. Stabilize imminent threats at uncontrolled hazardous waste
sites through Superfund removal and enforcement actions.
2. Use all available authorities to complete long terra hazardous
waste site clean-up including: Superfund Remedial program,
Superfund Enforcement program, RCRA Corrective Action permits
and RCRA Corrective Action enforcement. Pursue cost recovery
where Fund expenditures are involved.
3. Take enforcement actions to reduce the number of RCRA Class I
violations by major hazardous waste handlers and enforce
compliance with issued permits, paying special attention to
ground-water monitoring, closure, post-closure and financial
responsibility requirements.
4. Issue Part B RCRA permits, giving highest priority to those
facilities where there are the greatest potential environmental
risks or those which provide alternatives to land disposal.
5. Pursue the acid deposition research and analysis program.
Consider issues of damage to lakes and forests, long range
transport, and control technology. Work closely with th© States
on standby regulatory mechanisms.
6. Promulgate RCRA regulations and take other actions to strengthen
the existing RCRA program and carry out RCRA reauthorization
requirements. In particular, address alternatives to land disposal
for hazardous wastes, including disposal in the marine environ-
ment. Promulgate regulations for underground storage tanks,
air emissions from treatment, storage and disposal facilities,
and ocean disposal.
7. Reduce significant risks from existing chemicals. Initiate and
promulgate regulatory actions under the TSC^ existing chemicals
program. Accelerate re-registration of pesticide products and
conduct special reviews where cancellation and suspension may
be necessary to mitigate unwarranted health and environmental
risks.
8. Address hazards from asbestos by strengthening the asbestos in
schools and public buildings programs. Promulgate and enforce
other regulations to address commercial manufacture, use of
asbestos products, and exposures to asbestos in public buildings
or ambient air (under Clean Air Act) as necessary.
9. Achieve and maintain compliance with air quality standards in
nonattainment areas, especially for ozone.This should
include increasing continuous compliance by reflated facilities,
ensuring compliance by new and in-use vehicles, af&d nwmitoring
implementation of revised SIP schedules.
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-2-
10. Implement the National Municipal Policy to ensure the construction
and effective operation of municipal facilities and take enforce-
ment actions to improve compliance with industrial and municipal
NPDES permit requirements.
11. Complete reissuance of NPDES major and environmentally signi-
ficant minor facility permits. Apply the new treatment require-
ment contained in the revised effluent guidelines and, where
necessary, water quality based limits derived from water quality
standards and use of effluent toxicity monitoring.
12. Implement the ground water protection strategy by supporting the
development of State programs and addressing uncontrolled
sources of contamination; give priority to ground water contam-
ination resulting from hazardous wastes and pesticides.
13. Address drinking water contaminants by promulgating the drinking
water standards and expanding the program of issuing health
advisories for unregulated contaminants in support of Superfund
cleanup activities, State agencies' responses to contamination
incidents, and other purposes.
14. Protect wetlands through vigorous attention to reviews of
dredged and fill applications under Section 404 of the Clean
Water Act and enforcement actions against unpermitted activities.
15. Implement a comprehensive national strategy for the control of
hazardous air pollutants. Continue development and enforcement
of NESHAPs. Emphasize implementation of SIP and other program
measures that also reduce hazardous air compounds. Support
State and local agency efforts to assess and regulate specific
hazardous air pollutants.
16. Control indirect discharges by implementing the pretreatment
program, giving priority to: approving State pretreatment
programs; assessing the adequacy of approved pretreatment
programs; and enforcing categorical standards.
17. Work with States to incorporate water quality and sediment
criteria for toxics into State water quality standards;
issue additional water quality and sediment criteria for
toxics; revise waste load allocations for water quality-
limited segments to include toxic limits.
18. Implement an underground injection control program focusing
permit issuance and enforcement efforts on those existing
facilities that present the greatest threat to underground
sources of drinking water and on those new facilities
which must be permitted to prevent an unnecessary adverse
impact on oil and gas production. Implement the ban on
underground injection of hazardous waste into or above an
aquifer used for drinking water.
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19. Complete the review and revision of National Ambient Ait-
Quality .Standards as necessary. Provide support to State
and local agencies, including technical and procedural
guidance for the development of State Implementation Plan
(SIP) revisions necessitated by revised standards. Speci
fically, support the development of PM^o SIPs.
20. Work with States to incorporate nonpoint source control
measures in their water quality programs, where nonpoint
source pollution is a major problem in surface or ground
waters .
21. Work with States to develop and achieve high quality
programs under interim and final RCRA authorizations.
Make every effort to assist States in meeting criteria
for a quality RCRA program.
22. Implement a coordinated approach to solve multimedia pollution
concerns in discrete geographic areas. Identify candidate
areas and develop mutually agreed upon local, State, and
Federal plans to reduce risk to human health and the environ-
ment.
23. Ensure the Federal Government shows leadership in environmental
control practices through Federal facility compliance with air,
water, toxics and hazardous waste requirements.
24. Achieve compliance with PCB rules and regulations focusing
inspection and enforcement actions on the greatest potential
sources of harmful PCB exposure.
25. Promulgate regulations to implement a program for management,
reuse and, where necessary, disposal of municipal sewage
sludges .
26. Complete the regulatory program for control of exposure to
radioactive wastes. Public standards or guidance for
disposal of high-level and low-level radioactive wastes,
and for addressing residual radioactivity at decommissioned
nuclear facilities. Develop criteria for review of permit
applications for ocean disposal of radioactive wastes.
27. Implement the dioxin strategy.
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ATTACHMENT E : Summary ATS Report
8/28/84
ACTION TRACKING SYSTEM REPORT
Reporting Period 24 8/11/84 - 8/24/84
Summary; 36 items were due this period
16 were completed
17 (4)** remain overdue*
OAR
OARM
OEGM
OPPE
OPTS
ORD
OSWER
OW
Overdue from
Last Period
8
*
2
5
-
2
_6
23
Previous
Overdues New New Items *Currently Projects
Completed Items Completed Overdue Pending
4 1 - 4 (1) 3
^m ^ ^ «* ^
1 1
3 8 6 4 (2) -
1 1
1 - 3 (1) 2
_i _! _Z _§ -1
8 13 8 17 (4)** 8
Schedule
Changes
5
<«
2
-
2
-
_1
10
*Iteras for which the schedule was changed during the period are not counted as
"Currently Overdue".
**Number of projects of those currently overdue that are delayed due to extended
review by OMB is in parentheses (e.g., one of four OAR projects currently
overdue is pending at OMB).
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ATTACHMENT E; DETATT.RD ATS REPORT ATS Report 24
p. 9
SECTION II: OVERDUE ACTIONS
OSWER - 23 * Schedule Revisions: 3
i
Title : FEASIBILITY STUDY GUIDANCE
Desc : ISSUE-GUIDANCE TO ASSIST CONTRACTORS & OTHERS IN EVALUATING ALTERNATIVE
REMEDIAL ACTIONS WHICH MIGHT BE UNDERTAKEN AT A SUPERFUND SITE.
Original Current
Milestones Due Date Due Date
SUBMIT TO STEERING COMMITTEE 7/30/84 7/30/84
STEERING COMMITTEE MEETING 8/13/84 8/13/84
SUBMIT TO RED BORDER/OMB 9/ 4/84 9/ 4/84
ISSUE GUIDANCE 7/30/84 10/ 9/84
COMMENTS: OSWER IS PREPARING NECESSARY REVISIONS TO THE GUIDANCE. A NEW
SCHEDULE WILL BE SUBMITTED WHEN REVISIONS ARE COMPLETED AND
APPROVED BY DA.
QW - 2. * Schedule Revisions: 2
Title : BCT COST TEST & EFFLUENT GUIDELINES (REVISION)
Desc : REVISION OF COST REASONABLENESS TEST FOR BCT EFFLUENT LIMITATIONS
FOR PRIMARY & SECONDARY INDUSTRIES, MAINLY FOOD PROCESSORS/LIGHT
MANUFACTURERS.
Or ig i nal Current
Milestones Due Date Due Date
AA SIGNS FR NOTICE 7/24/84 7/24/84
OPTION SELECTION WITH DA 2/ 1/85 2/ 1/85
ADM SIGNS BCT METHODOLOGY 5/24/85 5/24/85
COMMENTS: OW EXPECTS AA'S SIGNATURE ON NOTICE WEEK OF 8/27/84.
OW - 5 * Schedule Revisions: 2
Title : NPDES REGULATION REVISIONS (LITIGATION PACKAGE)
Desc : THIS REGULATION WILL IMPLEMENT THE NPDES ISSUES IN THE 6/7/82
SETTLEMENT AGREEMENT IN NRDC V. EPA.
Original Current
Milestones Due Date Due Date
PUBLISH FRM IN FR 3/ 1/84 4/20/84
COMMENTS: SUBMITTED TO AX 8/22/84. DA WILL SIGN PACKAGE. ADM HAS RECUSED
HIMSELF.
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ATTACHMENT E; Detailed ATS Schedule
ACTION TRACKING FORM
1) ATS NUMBER: OSWER 023
2) ACTION ITEM TITLE: Feasibility Study Guidance
3) AUTHORITY: CERCIA Section 105
4) DESCRIPTION: Issue guidance to assist contractors and others in evaluating
« alternative remedial actions which might be undertaken at a
Superfund site.
5) STATUTORY OR COURT-ORDERED DEADLINE: None
6) EARLY DECISION OR POLICY
DIRECTION BY ADMINISTRATOR
NEEDED? (MILESTONE NUMBER): f2 Level I Rules
7) PROGRAM CONTACT (NAME AND PHONE *): Jim Lounsbury 382-2441
REPORTING
ORIGINAL CURRENT DATE PERIOD
DUE DATE DUE DATE COMPLETED WHEN DUE
MILESTONES
1) Distribute Options Paper
2) Options Review Meeting
3) Additional milestones to OMSE
4) Continents due from AAS
5) Remaining issues identified
6) Additional milestones to OMSE
7) Resolve issues with OPPE
8) Submit to Steering Committee
9) Steering Committee meeting
10)Submit to Red Border/OMB
11)Issue Guidance
3/11/84
3/21/84
4/6/84
4/13/84
4/20/84
5/4/84
6/14/84
7/30/84
8/13/84
9/4/84
7/30/84
3/11/84C
3/21/84C
4/6/84C
5/4/84C
5/11/84C
6/1/84C
6/27/84C
7/30/84L
8/13/84L
9/4/84L
10/9/84T
3/12/84
3/23/84
4/9/84
5/8/84
5/16/84
6/1/84
6/27/84
13
13
14
16 Note (2)
17
18
20
23 Note (5) (6
24 (7)
25
28
NOTE: A new schedule wiXl be submitted after options meeting is held March 21.
(1) 4/20/84 - Schedule change submitted due to delay in receiving
other AAs comments.
(2) 5/4/84 - Received Comments from OPPE/OW/OPTS, still awaiting others.
(3) 6/15/84 - Second schedule revision received due to change in AA's schedule
and long lead time required to publish document through ORD in Cincinatti.
(4) 7/13/84 - Schedule change submitted.
(5) 8/10/84 - New policy direction received from DA on "compliance with
other laws" which affects this guidance. New schedule will be submitted
after guidance is rewritten and approved by DA.
(6) 8/24/84 - Revisions to guidance are underway.
(7) 9/7/84 - Comments due from AAs/RAs by 9/12. New schedule will be
submitted then.
Schedule Revisions:
Note (3)(4)
Date Prepared; 9/7/84
* U.S. Government Printing Office : 1985 466-004/20718
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